Pursuant to Section 595(c) of Title 28, the Office of
Independent Counsel (OIC) hereby submits substantial and credible
information that President Clinton obstructed justice during the
Jones v. Clinton sexual harassment lawsuit by lying under oath
and concealing evidence of his relationship with a young White
House intern and federal employee, Monica Lewinsky. After a
federal criminal investigation of the President's actions began
in January 1998, the President lied under oath to the grand jury
and obstructed justice during the grand jury investigation.
There also is substantial and credible information that the
President's actions with respect to Monica Lewinsky constitute an
abuse of authority inconsistent with the President's
constitutional duty to faithfully execute the laws.

There is substantial and credible information supporting the
following eleven possible grounds for impeachment:

1. President Clinton lied under oath in his civil case when
he denied a sexual affair, a sexual relationship, or sexual
relations with Monica Lewinsky.

2. President Clinton lied under oath to the grand jury
about his sexual relationship with Ms. Lewinsky.

3. In his civil deposition, to support his false statement
about the sexual relationship, President Clinton also lied under
oath about being alone with Ms. Lewinsky and about the many gifts
exchanged between Ms. Lewinsky and him.

4. President Clinton lied under oath in his civil
deposition about his discussions with Ms. Lewinsky concerning her
involvement in the Jones case.

5. During the Jones case, the President obstructed justice
and had an understanding with Ms. Lewinsky to jointly conceal the
truth about their relationship by concealing gifts subpoenaed by
Ms. Jones's attorneys.

6. During the Jones case, the President obstructed justice
and had an understanding with Ms. Lewinsky to jointly conceal the
truth of their relationship from the judicial process by a scheme
that included the following means: (i) Both the President and
Ms. Lewinsky understood that they would lie under oath in the
Jones case about their sexual relationship; (ii) the President
suggested to Ms. Lewinsky that she prepare an affidavit that, for
the President's purposes, would memorialize her testimony under
oath and could be used to prevent questioning of both of them
about their relationship; (iii) Ms. Lewinsky signed and filed the
false affidavit; (iv) the President used Ms. Lewinsky's false
affidavit at his deposition in an attempt to head off questions
about Ms. Lewinsky; and (v) when that failed, the President lied
under oath at his civil deposition about the relationship with
Ms. Lewinsky.

7. President Clinton endeavored to obstruct justice by
helping Ms. Lewinsky obtain a job in New York at a time when she
would have been a witness harmful to him were she to tell the
truth in the Jones case.

8. President Clinton lied under oath in his civil
deposition about his discussions with Vernon Jordan concerning
Ms. Lewinsky's involvement in the Jones case.

9. The President improperly tampered with a potential
witness by attempting to corruptly influence the testimony of his
personal secretary, Betty Currie, in the days after his civil
deposition.

10. President Clinton endeavored to obstruct justice during
the grand jury investigation by refusing to testify for seven
months and lying to senior White House aides with knowledge that
they would relay the President's false statements to the grand
jury -- and did thereby deceive, obstruct, and impede the grand
jury.

11. President Clinton abused his constitutional authority
by (i) lying to the public and the Congress in January 1998 about
his relationship with Ms. Lewinsky; (ii) promising at that time
to cooperate fully with the grand jury investigation; (iii) later
refusing six invitations to testify voluntarily to the grand
jury; (iv) invoking Executive Privilege; (v) lying to the grand
jury in August 1998; and (vi) lying again to the public and
Congress on August 17, 1998 -- all as part of an effort to
hinder, impede, and deflect possible inquiry by the Congress of
the United States.

The first two possible grounds for impeachment concern the
President's lying under oath about the nature of his relationship
with Ms. Lewinsky. The details associated with those grounds
are, by their nature, explicit. The President's testimony
unfortunately has rendered the details essential with respect to
those two grounds, as will be explained in those grounds.